A&O Shearman global insights

OECD Pillar Talk - Domestic Implementation of Pillar Two


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Domestic Implementation of Pillar Two is a new podcast that considers the domestic implementation by each of the UK, Dutch and German governments of the Organisation for Economic Co-operation and Development’s (OECD) Pillar Two rules imposing a global minimum corporation tax rate of 15%.

Pillar Two is the series of rules designed and agreed by OECD Inclusive Framework jurisdictions with a view to setting a global minimum corporation tax rate of 15% on certain multinational groups of companies.

Moderated by tax associate Mitchell Fraser (London), this podcast features senior tax associate Sorsha Reilly (London) and tax associates Charlotte Hoff (Amsterdam) and Christoph Zilgens (Dusseldorf) in a discussions about the implementation of Pillar Two in their respective countries. Specifically, the speakers consider a range of topics, including:  

A brief overview of the Pillar Two rules

  • How the effective tax rate for Pillar Two purposes is determined and the different types of top-up taxes
  • The OECD’s proposed timetable for jurisdictions to implement these rules
  • An update on the implementation of the Pillar Two rules in the UK, the Netherlands and Germany
  • Differences between the UK, Dutch and German Pillar Two proposals.
  • OECD Pillar Talk is Allen & Overy’s new series of webinars, podcasts and publications. The series focuses on global tax changes being implemented as a result of the two-pillar proposals initiated by the Organisation for Economic Co-operation and Development (OECD).

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